ML20209J053
| ML20209J053 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 08/16/1985 |
| From: | Delgeorge L COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 0517K, 517K, NUDOCS 8511110340 | |
| Download: ML20209J053 (10) | |
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Commonwealth Edison -
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'J Address Reply to: Post Office Box 7G7 '
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~ Mr. James-G. 'Keppler Regional Administrator U.S.~ Nuclear ~ Regulatory Commission Region;III
~799 Roosevelt Road Glen Ellyn, IL.' 60137
Subject:
LaSalle County Station Units 1 and 2 Response to Inspection Report
- Nos. 50-373/85-017 and 50-374/85-017 NRC Docket Nos. 50-373 and 50-374 Reference (a):
W. D. Shafer letter to Cordell Reed dated July 18, 1985.
Dear Mr. Keppler:
This letter is in response to the inspection conducted by Messrs.
M. Jordan, J. Bjorgen, R. Kopriva, and A. Januska on May 14 through June 19, 1985, of activities at LaSalle County Station. Reference (a) indicated that certain activities appeared to be in noncompliance with NRC requirements.
The Commonwealth Edison Company's response to the Notice of Violation is provided-in the attachment.
If_ you have any further questions regarding this matter, please direct.them to this office.
Very truly yours,_
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L. O. DelGeorge Assistant Vice President im Attachment cc: NRC Resident Inspector - LSCS AUG1g198$
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m ATTACfNENT RESPONSE TO-NOTICE OF VIOLATION ITEM OF NONCOWLIANCE~
1.
10 CFR 50 Appendix.B, Criterion II, as implemented by Commonwealth Edison-Company's Quality Assurance Program, Quality Requirement 2, commits to Regulatory Guide 1.28 which invokes the requirements of ANSI-N45.2-1977 for the control of activities affecting quality.
ANSI'N45.2, Section 7 states, in part, that measures shall be established to assure that documents are reviewed for adequacy to preclude the possibility of the use of inappropriate documents. ANSI N45.2, Section 12 states, in part, that test prerequisites include the condition of the item to be tested. ANSI N45.2, Section 15 states, in part, that measures shall be established to prevent inadvertent operation of systems and components.
Contrary to the above:
a.
Measures were not established to prevent inadvertent actuation of the Unit 2 Reactor Protection System (RPS) received on May 10, 1985 while in cold shutdown. The B RPS channel had a 1/2 scram signal due to troubleshooting the 8 Main Steam Line Radiation Monitor.
Channel A of the RPS actuated due to lack of communication between the unit operator and the instrument mechanic on which Intermediate Range Monitor (IRM) should have been left bypassed.
b.
Testing prerequisites did not include the condition of the item to be tested, to prevent an inadvertent Group-I Primary Containment Isolation System (PCIS) signal by Unit 2 on May 31, 1985.
The Electro-Hydraulic Control (EHC) logic indicated main steam turbine speed of 1800 RPM, and the logic for the Group I isolation on low condenser vacuum was no longer bypassed. Thus, when the turbine reset button was pressed by the reactor operator, the Group I isolation occurred.
I c.
Measures-were not established to assure that documents were reviewed for adequacy of the test prerequisites regarding the condition of the item to be tested. This resulted in four i
inadvertent RPS scram signals on Unit 2:
(1) On June 4, 1985, the Source Range and Intermediate Range Neutron Monitoring Systems were being tested and the Reactor Mode Switch was placed in startup. The Control Rod Drive (CRD) System was shutdown at the time and the low CRD header
. pressure scram actuated.
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On_' June 16, 1985, the Reactor Mode Switch was placed in startup with the Scram Discharge Volume (SDV) level above the scram setpoint.
(3) On June 16; 1985, the Reactor Mode Switch was placed in run
-with the Main Steam Isolation Valves (MSIV) closed.
(4) On June 7,1985, while testing the RPS logic (LES-RP-02) a scram signal was received by lifting leads for testing of the backup scram circuitry.
CORRECTIVE ACTION TAKEN-AND RESULTS ACHIEVED
-a.. This event occurred as a result of established trouble shooting techniques. Spiking had been observed in the 'C' intermediate range neutron monitoring channel. After initial investigation had failed to locate the cause, the 'G' and.'C' detectors' cabling was
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reversed under the reactor vessel in order to determine whether the cabling or the detector was defective. System design only allows bypassing one of these two chamels at a time. Because it was thought to be more likely that the detector was bad, the 'G' 4
channel, with the 'C' detector was left bypassed. This condition remained for twelve hours waiting for the spiking to recur. On May 10,-1985, the technicians were trouble shooting a separate problem on the 'B' Main Steam Line radiation monitor. This radiation monitor had spiked once at 0145 and the technicians were~ asked to take a look at it. During their initial investigation the drawer was in a tripped condition. During this period the 'C' IRM tripped due.to the cabling causing a spike. The 'C' IRM.was bypassed and the scram was reset. Because the unit was in cold shutdown at the time, no rod movement occurred. During subsequent troubleshooting of the radiation monitoring drawer, when it became apparent that a quick fix was not likely, a jumper was installed to block the scram signal from.the instrument. This trip signal is not required to be operable while in cold shutdown.
.b.,c.. For all of these actuations the initiating event was identified and J
resolved, and the logic restored to standby. Because the unit was in cold shutdown at the time, the equipment actuated was already in its tripped condition ~(rods full in, MSIV's shut).
CORRECTIVE ACTION TAKEN TO AVOID FURTFER NONCOWLIANCE a.
- The faulty IRM channel-was found to have a loose connector. The radiation monitor had a bad zener diode. These were both repaired.
... b.,c.
These events were reviewed with all SCRE's and NS0's to ensure that personnel think through the consequences of the steps which are taken during the performance of procedures. In addition:
1.
The procedure for backfeeding a shutdown unit from the Uni.t Aux transformer has been revised to require the use of caution cards warning the NSO of the artificial 1800 RPM signal and the possibility of a Group I isolation if the turbine is reset under these conditions.
2.
A new procedure, LOP-AA-03 has been developed. This procedure delineates all of the changes in RPS, ESF, and rod block logic and setpoints which occur in each change of the mode switch.
This procedure will assist the operators in recognizing potential actuations so that appropriate preventative actions may be taken.
3.
LES-RP-02 is undergoing revision to prevent a scram signal when lifting leads for testing the backup scram circuitry.
This revision is expected to be complete by October 1, 1985, well ahead of the next time it will be used.
DATE OF FULL COMPLIANCE Full compliance has been achieved.
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- ITEM OF NONCOWLIANCE 2.
Technical Specification 6.2.A.7 states that detailed written procedures "shall be prepared, approved and adhered to" for surveillance and testing requirements.
Contrary to the above, the procedure for performing the calibration of two Automatic Depresurization System actuation level switches on March 31, 1985 was not "edhered to", which allowed returning the inoperable B Trip System to service.
CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED a.
An investigation indicated that the subject instruments were changed out with an environmentally qualified model under modification M-1-1-84-091 and subsequently declared operable on July 31, 1985, following performance of a post-maintenance test (LIS-NB-104). The switch was wired in accordance with wiring diagram lE-1-4650AA rev. S4 which designated that normally closed contacts be used. This is in conflict with system design and schematic diagram 1E-1-4201AH rev. H1 which require normally open
- contacts, b.
The post maintenance testing was reviewed, and it was determined that the test should have been adequate to demonstrate operability.
The instrument maintenance technicians (1 CST and 1 B man) were interviewed regarding their actions in performing the survellance.
The CST showed thorough understanding of the procedure and methods used for calibration. The B-man was able to explain his involvement and showed confidence that the job was performed properly. It was noted, however, that the switches were relocated by this modifica-tion and this was the first time the switches had been calibrated in their new locations.
In the new locations, the CST cannot see his test instruments and must rely on the 8 man to interpret the meter responses.
c.
The switches (1821-NO37BA, 1821-NO37DA) were rewired correctly.
d.
All Unit 1 & 2 instruments with similar potential that were modified by an Environmental Qualification (EQ) modification were verified correct in the field. This was accomplished for modified instruments declared operable prior to April 17, 1985, e.
A design review of EQ modifications was performed to ensure that no additional errors of this type existed.
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- CORRECTIVE ACTION TAKEN-TO AVOID FURTHER HONCOWLIANCE Procedu're LIS-NB-104 was revised to minimize the potential for a.
future errors.
b.. All Instrument Maintenance procedures which may contain similar potential for error are being reviewed and will be clarified if necessary, by July, 1986.
DATE OF FULL COWLIANCE-Full compliance has been achieved.
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3.
Title 10 to the Code of Federal Regulations (10 CFR), Part 50, Appendix B, Criterion III, states, in part, " Measures shall be established for the identification and control of design interfaces, and Jfor coordination among participating design organizations. These measures shall include the establishment of procedures among participating design organizations for the review, approval, release, distribution, and revisiori of documents involving design interfaces." The licensee implemented this requirement by Quality Assurance Manual Procedure QP No. 3-51c Step C.6.C of QP No. 3-51 requires the Station Nuclear Engineering Manager (SNEM) to " Prepare required detailed engineering design documents' necessary drawings plus establish quality requirements and other supporting documentation requirements."
Contrary to the above, drawings which were issued to the site for the environmentally qualified switch replacement were issued with incorrect wiring, making the System B for ADS be inoperable which resulted in the Technical Specification 3.3.3 Limiting Condition for Operation to be exceeded.
CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED The error in question stems from an inconsistency between the pertinent schematic diagram, which correctly identified the switch contacts to be wired, and the corresponding wiring diagram, which erroneously identified the opposing switch contacts. Although this inconsistent information was in fact transferred to the site via design documents, all procedures for the preparation, review and issuance of design documents were adhered to. This' situation represents an isolated instance where an error was undetected by the ' preparer of a design document and' subsequent reviewers. In no instance was there a failure by CECO to either have in place or follow approved procedures. Further discussion is provided below.
Per SNED Procedure Q.ll, the review of Detail Design Drawings, including wiring and connection drawings, is delegated to the Architect-Engineer.
Sargent & Lundy acted as the designer for the modification in question.
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Immediately following the discovery of this error, the following l'
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" corrective actions were taken:
11 The error was corrected via a Field Change Request (FCR).
~2.
- All Unit 1 and Unit-2 instruments which had been recently modified
.and returned to service prior to April 17, 1985 and which had the
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' capacity for a similar error were verified in the field to be installed correctly.
f 3.-
A design review was completed by Sargent & Lundy of similar electrical Engineering Change Notices (ECNs) associated with the
. Environmental Qualification (EQ) modifications. This review involved eight (8) ECNs'and was completed prior to declaring operable any. switch for'which a modification was in progress. Only one other similar error was' identified where the schematic and corresponding wiring diagrams were inconsistent. The' physical work for that' application (2821-N020A) had not yet been started. The affected design documents were corrected via a Field Change Request prior to commencement of the switch replacement.
Additionally,Ta Special Generic Audit was. conducted at Sargent & Lundy between April.25 and May 10, 1985. This audit involved a review of
, selected ECNs issued after May 1,1984 for LaSalle as well as modification packages.for Dresden, Quad Cities, and Zion Stations and encompassed 280 schematics and 519 associated wiring diagrams. Only five wiring ~ diagrams in addition to those' identified previously were found to contain inconsistent information. These were all associated with LaSalle; no errors of'this' nature were found fo.t Dresden, Quad Cities, and Zion. Installation work for the five wiring diagrams in question had not been started such that there is no immediate-
- implication'on plant safety. These errors will be corrected prior to the commencement of installation.
. Based.on. the low incidence of these types of errors, the quality of design documents with regard to consistency of information is judged to be high. The error which led to this situation'is considered isolated and not' indicative of a programmatic weakness.
CORRECTIVE ACTION TAKEN TO AVOIO FURTHER NONCOW LIANCE Based ori ~the findings of Sargent & Lundy's Special Generic Audit, errors -
'of this nature do not exist or are being eliminated for existing ECNs such that all design documents presently transferred to the site will be consistent and do not have the same potential for misinstallation.
8-With regard to the issuance of future ECNs, Sargent & Lundy has taken the following actions:
1.
The Electrical Design and Drafting (Wiring) personnel assigned to the LaSalle Project were yetrained (a) in the use of the project instruction covering the processing of Sargent & Lundy ECNs, and (b) in the' application of the Sargent & Lundy standard covering the preparation and review of design drawings including schematic diagrams and wiring diagrams.
2.
The' project instruction covering the processing of ECNs was revised to include a requirement that each page of the ECN which is a diagram or drawing (including reproduction of all or part of a design document) shall be (a) individually signed by the Preparer and the Reviewer of that page, and (b) processed in the same manner as Sargent & Lundy drawings.
3.
At a regular meeting'of the ED&D supervisory personnel assigned to Nuclear Services Projects, the importance of accuracy on all drawings was reerrphasized and the supervisory personnel were reminded that time shall be allotted in their schedules to allow the Reviewer of a drawing adequate time to follow the applicable Sargent & Lundy procedures and perform a proper review of the drawings.
4.
The types of errors found in the audit, their cause, and the proposed corrective actions were reviewed at a regular Nuclear Project Meeting which is attended by the Electrical Project Engineers assigned to all nuclear projects and by a representative from C&I Division.
5.
The Electrical Department standard review guides for schematic diagrams and the review guides fcr wiring diagrams were reviewed to
-determine what improvements could be made to the guideline to assist the ED&D personnel in the preparation and review of scheer.atic and wiring diagrams.
DATE WFEN FULL CDWLIANCE WILL BE ACHIEVED 1.
The wiring diagrams found to be inconsistent with the corresponding schematic will be or were corrected as follows:
a.
A supplemental ECN ED-lll-1 was issued on July 18, 1985.to revise Drawings lE-2-4622AA, lE-2-4622AC, and lE-2-4624AB (ECN No. ED-lll).
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Supplemental ENCs will be issued to revise Drawings lE-2-4656AC (ECN No. ED-61) and lE-1-4656AC (ECN No. ED-87) by October 1, 1985.
2.
The Electrical Design and Drafting (Wiring) personnel for the LaSalle Project were retrained on July 1, 1985.
3.
The revised project instruction for processing ECNs was issued May 22, 1985.
4.
The meeting of ED&D supervisory personnel, in which the importance of accuracy of all drawings was reemphasized, was held on May 20, 1985.
5.
The Nuclear Project Meeting, in which the type of errors found in the audit was discussed, was held on May 20, 1985.
6.
The Electrical Department standard review guides were revised and issued on July 10, 1985.
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